Transcript Insert Client Name/ or Name of Presentation

What Happens When You
Pull the Plug?
What COPS Means to Your Facilities
Presented by
Vincent Plansky, PE, LEED BD+C
August 11, 2010
NEC 2008 Article 708
Critical Operations Power
Systems (COPS)
708.1 Scope - Applies to power systems, HVAC,
fire alarm, security, communications, and
signaling systems in facilities classified as
“critical” by:
 Any governmental agency having jurisdiction
 Municipal, state, federal, or other codes
 Facility engineering documentation establishing
the necessity
Regulatory Chain of Command
• Homeland Security Strategy and Legislation
• Presidential Directives
• National Initiatives
Federal
Government
Department
of Homeland
Security
• National Infrastructure Protection Plan (NIPP) Base Plan (2007)
• Requires development Sector Specific Plan (SSP) by the various
SSA’s
• Grants Enforcement Power to US EPA
US EPA is the
Water SSA
State and Local
Agencies
Owner
• Responsible for development of the process for risk-based
prioritization of its assets in the Water Sector
• Integrates federal protection efforts for Critical Infrastructures
and Key Resources (CI/KR) into the Water Sector
• Primacy authority to oversee SDWA drinking water
programs within its borders
• Regulates wastewater programs under the CWA’s
National Pollutant Discharge Elimination System
(NPDES) program.
2008 NEC Adoption by State
ME
WA
ND
MT
MI
VT
MN
NH
MA
NY
OR
WI
ID
CT
SD
WY
PA
IA
NB
NV
IL
NJ
MD
OH
IN
DE
WV
UT
VA
CO
CA
MO
KS
KY
Expected
January 2011
NC
TN
State
Adopted
AZ
SC
AR
NM
OK
GA
TX
MS
State Adopted
Unincorporated
Areas
AL
LA
AK
S. Carolina Code
Council adopted
2009 IRC with 2008
NEC 3/22/10 with
implementation
1-1-11
FL
Basically 2002 NEC
but some islands back
to 1993 NEC
Revised October 30, 2009
RI
MI
2008 NEC – 34 States
2005 NEC – 6 States
Local Adoption – (10)
Note: Some local adoption states have earlier than 2005 adoptions in some jurisdictions
May be applied to entire
facilities or to designated
areas within a facility
708.2 Definitions
Critical Operations Power Systems (COPS)
Power systems for facilities or parts of facilities that
require continuous operation for public safety,
emergency management, national security, or
business continuity.
Designated Critical Operations Areas (DCOA)
Areas within a facility or site designated as requiring
critical operations power.
Critical infrastructure is
“critical” for a reason
Water and wastewater facilities can be
classified as critical infrastructure
because they:
 Protect public health and safety
 Expedite disaster recovery
 Safeguard the environment
 Allow businesses to function
The Reliability of the Water Sector
Depends on a Complex Power Grid
Wholesale
Suppliers
Independent Power
Generators
Investor Owned Utility
Generators
Power
Marketers
Power
Exchange
(RTOs/ISOs)
Transmission
Pump
Stations
Water
Plants
Wastewater
Plants
Retail Electricity
Providers
The Electric Power Industry Before 2005
North American Electric Reliability Council (NERC)
 Ten Regional Reliability
Councils
 140 control areas
 18 Reliability Coordinators
 Managed reliability and
operation of wholesale markets
 No Enforcement Powers
 Voluntary Membership
 Voluntary Cooperation
 Competing interests
2003 – The Tipping Point
 Trouble began at 12:15 PM
 Inadequate situational awareness by FirstEnergy
 Inadequate tree-trimming by FirstEnergy
 345kV Sammis–Star overload trip at 4:06 PM –
essentially complete by 4:13 PM
 High speed cascading lasted approximately 12 seconds
 263 power plants shut down (531 generating units)
 Over 50 million people in the Northeast US and the
Province of Ontario were out of power up to 3 days
The Energy Policy Act (EPAct) of 2005
The Reorganization
 NERC reorganized as the
North American Electric
Reliability Corporation
 Granted powers to enforce its
own reliability standards
 Consolidation of Regional
Entities
 131 Balancing Authorities
(BAs)
NERC’s mission:
To ensure the reliability of the bulk
power system in North America.
EPAct and the Energy Markets
FERC:
Regulates the transmission and
wholesale sales of electricity in
interstate commerce.
RTOs and ISOs:
 Serve roughly two-thirds of all
US electricity customers
 Operate organized wholesale
electric markets
 Provide transmission service
 Interconnect new resources to
the transmission grid
 Financial interests must be
kept at arms length from
reliability interests
State Public Utility Commissions:
Regulate retail electricity sales to
consumers.
Traditional Risks to
Electrical Infrastructure
Generation
Failures
Vegetation
Generation
Transmission
Equipment
Failures
Storms
Local Distribution
Lightning
Floods
Emerging Risks to the
Electrical Grid
Variable
Generation
Physical
Security
Aging
Workforce
Economy
Source: NERCs 2009 -2018 Long-Term Reliability Assessment
Cyber
Security
Shift toward renewable energy
will affect grid reliability
Variable Generation is the term for generation based on
renewable fuel sources such as wind and solar.
 NERC’s 2009 Long-Term Reliability Assessment
estimates that 229,000 MW of wind generation resources
may be added by the year 2018.
How variable generation affects the reliability of the bulk
power system:
 Power output changes according to wind or weather
 These resources are not dispatchable to grid operators
 Renewable sources are less predictable than
conventional generation.
Section 215 of the
Federal Power Act:
§215(a)(8) “The term
‘cyber security
incident ’ means a
malicious act or
suspicious event that
disrupts, or was an
attempt to disrupt, the
operation of those
programmable
electronic devices
and communication
networks including
hardware, software
and data that are
essential to the
reliable operation of
the bulk power
system.”
The Smart Grid - Challenge
or Opportunity?
While the smart grid promises to bring greater efficiency
and functionality to grid operators, it also poses a
significant security challenge.
 NERC assessment - much of the grid is vulnerable to
cyber attack.
FERC examined AURORA compliance:
 Only 7 of 30 companies had mitigated the vulnerability
 Only 2 of 30 had a good cyber security posture.
Pulling the Plug on the Grid
Article 708 requires critical systems to
operate indefinitely while completely cut
off from the electric, gas, and water
utility grids.
Successful compliance requires:
 Planning and Assessment
 Engineering Beyond Traditional Approaches
 Rigorous Maintenance
 Planning
Risk Assessment (708.4)


1. Conduct Risk Assessment per
NFPA 1600 “Disaster/Emergency
Management and Business
Continuity Programs”
2. Identification of natural and man
made hazards
3. Assess specific vulnerability of the
electrical system
4. Develop mitigation strategy
 Planning


Physical Security (708.5)
1. Review Vulnerability Assessments
2. Restrict Unauthorized Access
3. Develop Security Plan
 Planning


Emergency Operations Plan
(708.64)
1. Documented emergency operations
plan
2. NFPA 1600, Section 5.7
3. Consider emergency response,
recovery, and continuity of operations
4. Identify internal and external roles and
responsibilities

 Engineering

Power Sources (708.20)
1. Generator Set
2. Fuel Cell
3. UPS
4. Storage Battery
A portable, temporary, or redundant alternate power
source shall be available for use whenever the COPS
power source is out of service for maintenance or repair.
Generator sets (708.20F)
1. Onsite fuel supply independent of
public utility gas system
2. Cooling systems independent of
municipal water supply
3. Single generator requires a means to
connect a backup portable generator
4. Automatic starting and transfer on
failure of the normal service
Fuel Cells
 Methane produced from
anaerobic digester used as the
fuel
 Ultra-low emissions
 Heat byproduct used to heat
the sludge.
 Up to 80% CHP efficiency.
 Biogas is a renewable fuel
2.8 MW, 13.8 kV Fuel cell
Courtesy of FuelCell Energy, Inc.
eligible for incentive funding
for projects in 28 states
including the Central States

 Engineering

Capacity of Power Sources
(708.22)
1. Capacity & rating for continuous
operation all loads simultaneously
2. Selective load pickup, load shedding,
and peak load shaving allowed
3. 72 Hr minimum duration of operation
4. Ventilation required

Transfer Equipment (708.24)
 Engineering

1. Means of bypass and isolation
2. Automatic transfer switches – listed,
electrically operated, mechanically
held
3. Use only for COPS loads

 Engineering

COPS Distribution Equipment
(708.11)
1. COPS branch circuit distribution
equipment located within DCOA
served
2. Located in 2 Hr rated fire resistant
spaces
3. 100 year floodplain protected
4. Surge protection devices at all
voltage levels (708.20)

 Engineering

Feeder & Branch circuit wiring
(708.10)
1. Identification of boxes, enclosures,
receptacles used for COPS
2. Separate raceways from non-COPS
3. COPS branch and feeders circuits
supplied by COPS shall be used only
on COPS equipment.

 Engineering

COPS Feeder Circuit Wiring
(708.10C)
1. Protect against physical damage
a. RMC, IMC, MI cable
b. PVC, EMT in 2” concrete
2. 1 Hr rated fire protection or 2”
concrete encasement
3. Above 100 year floodplain or listed
for wet location

 Engineering
HVAC, Fire Alarm, Security,
Emergency Communications,
and Signaling systems (708.14)

1. 2 Hr fire ratings
2. Twisted shielded pairs
3. Continuous shields
4. Fiber optics between buildings
5. 600v cables for signals 50v & up
6. Secondary protectors

Overcurrent Protection (708.50)
 Engineering

1. Devices accessible to authorized
2.
3.
4.
5.
persons only
Ground fault protection on next level
Ground fault testing
Full selectivity
6 cycle minimum coordination
between service and feeder

Commissioning (708.8)

1. Commissioning plan – NFPA 70B
 Maintenance
“Recommended Practice for
Electrical Equipment Maintenance”
2. Independent component & system
tests
3. Test results establish a baseline to
measure future performance
4. Annex F - Functional Performance
Tests (FPTs)

Testing & Maintenance (708.6)

 Maintenance
1. Witness test by AHJ
2. Periodic testing thereafter - schedule
acceptable to AHJ
3. Documented preventative maintenance
program per NFPA 70B required by AHJ
4. Written records
5. Testing under load – NFPA 110 Standby
& Emergency Power Systems
Funding Opportunities
FEMA Pre-Disaster Mitigation (PDM) Program
 PDM program funds plans and projects that reduce
overall risks to the population
 Awarded on a competitive basis without reference to
state allocations
CHP and biomass/biogas funding
opportunities
Energy Efficiency and Conservation
Block Grant (EECBG)
Stimulus Package – $37B for energy
efficiency and clean energy
U.S. Department of Energy (DOE) –
$27.1B in proposed FY2010 budget
State and Local – State Energy
offices and local utilities host
multiple programs for energy
incentives and rebates
Emissions
GHG
Pollutants
Fuel Cells are a Green
Power Opportunity
Supplemental
Utility Gas
Power
Generation
Gas
Cleaning
CH4
Landfill Gas
Collection
Gas
Storage
Fuel Cell
CH4
WWTP Digesters
Open Discussion
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Cambridge, MA
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